The Horizon Europe CRM-geothermal project: Guidance on the internalisation of ESG requirements for the combined extraction of heat and minerals

The digital and energy transition in the European Union and worldwide implies an increasing need of raw materials that need to be mined, and provision of Critical Raw Materials (CRM) for the EU is usually linked to import dependency. A potential additional source of CRMs and an alternative to conventional mining could be the exploitation of geothermal reservoirs, as geothermal brines often contain high concentrations of metal ions. The EU-funded ‘CRM-geothermal’ project aims to open up the potentially huge untapped resource of raw materials from geothermal fluids and provide operators and investors with information needed to assess the viability of the approach of co-extraction heat and minerals from geothermal fluids. Every project for the extraction of minerals has to be subject to a PESTEL (political, environmental, societal, technological, economic, legal) analysis to assess its viability. The combined extraction of heat and minerals is no exception even though it would not be a classical mining project with respect to the impacts and legacies it may create. Although it has been shown that any environmental impacts from projects that extract raw materials from geothermal brines will be low, this has to be demonstrated not only to the regulatory authorities, but also to public stakeholders with a view to create trust. A key element of trust-building is a comprehensive assessment of potential risks and impacts together with proposals for their adequate management. In other words, the ESG requirements have to be fully internalised into the project planning process. In this document, a scheme for the internalisation of ESG requirements is presented, to be implemented through a check-list to accompany the development of combined extraction sites. The check-list takes prospective operators through several steps that help them identify ESG risks along the life-cycle of a facility. The operators are thus enabled to address these potential ESG risks before they become active risks. The report also introduces a reporting standard for sustainability aspects as additional guidance. The societal and economic aspects feeding into the PESTEL assessment are subject of complementary CRM-geothermal reports, which are informed by the risk assessments laid out in this report. This document is an extract from CRM-geothermal Deliverable 4.1: Falck, W. E. & Correia, V., The Horizon Europe CRM-geothermal project: Deliverable 4.1 – ESG due diligence of the combined extraction of CRMs and energy, incl. UNFC/UNRMS compatible reporting and policy recommendation, Zenodo, 2025, DOI: 10.5281/zenodo.17235755.